Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
State tax department directs strict procedures for assessing whether to file appeals or revisions against appellate tribunal orders that prejudice revenue, requiring assessing and intelligence officers to scrutinize orders for erroneous decisions or unresolved questions of law, prepare fact-based, reasoned remarks, obtain in-house legal views where needed, and submit those remarks to supervisory Joint Commissioners for second-level evaluation before transmission to the Joint Commissioner (Law). Remarks must include a concise order summary, legal evaluation emphasizing error or question of law, and a reasoned recommendation on appeal; approved revisions will be monitored through the court process. These instructions take immediate effect.
State tax department directs strict procedures for assessing whether to file appeals or revisions against appellate tribunal orders that prejudice revenue, requiring assessing and intelligence officers to scrutinize orders for erroneous decisions or unresolved questions of law, prepare fact-based, reasoned remarks, obtain in-house legal views where needed, and submit those remarks to supervisory Joint Commissioners for second-level evaluation before transmission to the Joint Commissioner (Law). Remarks must include a concise order summary, legal evaluation emphasizing error or question of law, and a reasoned recommendation on appeal; approved revisions will be monitored through the court process. These instructions take immediate effect.
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